Swaps Reporting Requirements

News & Analysis as of

Extension of Time-Limited, Conditional No-Action Relief Regarding Masking Certain Reportable Identifying Information

On January 15, the Commodity Futures Trading Commission’s Division of Market Oversight (DMO) issued CFTC letter 16-03 (“Letter”) providing a conditional, time-limited extension of the relief provided in CFTC Letter 13-41,...more

Financial Services Weekly News - November 2015

Regulatory Developments - Client Alert: SEC Issues New Guidance on Excluding Shareholder Proposals under Rule 14a-8: Goodwin Procter’s Capital Markets practice has released a client alert on the SEC’s Division of...more

CFTC Brings Enforcement Action for Swap Reporting Violations

The Commodity Futures Trading Commission (CFTC) recently brought its first enforcement action arising from the Dodd-Frank requirement that swap transactions be reported to a registered swap data repository (SDR). The CFTC has...more

CFTC’s Division of Market Oversight Provides Additional Time to Comply with Electronic Reporting Requirements in the OCR Final...

On September 28, the U.S. Commodity Futures Trading Commission’s (the “Commission”) Division of Market Oversight issued a no-action letter that provides reporting parties additional time to comply with certain reporting...more

CFTC Zeros in on Large Trader Reporting

On September 17, 2015, the Commodity Futures Trading Commission (CFTC) issued an order filing and simultaneously settling charges against Australia and New Zealand Banking Group Ltd. (ANZ), an Australia-based firm that’s...more

Orrick's Financial Industry Week in Review

CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps - On August 19, The U.S. Commodity Futures Trading Commission (CFTC) proposed amendments to existing rules relating...more

Bridging the Week - August 2015 #4

CME Group Files Disciplinary Actions for Trading Ahead of Block Trades and Failure to Supervise an Employee Engaging in Disruptive Trading Activities - In two cases of first impression, CME Group exchanges brought and...more

CFTC Issues Proposed Amendments to Swap Data Recordkeeping and Reporting Requirements for Cleared Swaps

On August 19, The U.S. Commodity Futures Trading Commission (CFTC) proposed amendments to existing rules relating to swap data reporting in connection with cleared swaps. The amendments are aimed at providing additional...more

CFTC Further Extends Valuation Data Reporting Relief for SDs and MSPs

The Commodity Futures Trading Commission’s Division of Market Oversight (DMO) has further extended no-action relief from the valuation data reporting requirements for cleared swaps under CFTC Regulation 45.4(b)(2)(ii)....more

Financial Services Weekly News Roundup - June 2015 #3

Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more

SEC Proposes Additional Cross-Border Rules for Security-Based Swaps

If finalized, the proposed rule would be the SEC’s second major step toward finalizing the cross-border rules for security-based swaps under the Dodd-Frank Act. On April 29, 2015, the US Securities and Exchange...more

CFTC Proposes Relief from Trade Option Reporting and Recordkeeping Requirements for Commercial End Users

On April 30, 2015, the Commodity Futures Trading Commission (“CFTC”) approved for publication in the Federal Register proposed amendments to the trade option exemption (the “Proposal”) that would reduce reporting and...more

"CFTC Proposes to Reduce Trade Option Reporting Requirements for Commercial End-Users"

Trade options are physically settled over-the-counter options on most deliverable commodities (e.g., agricultural, energy, or metals) where the buyer is a producer, processor, commercial user or merchant of the commodity...more

Did The SEC Violate The Administrative Procedure Act?

Yesterday, Broc Romanek wrote about the joint dissent issued by Commissioners Daniel M. Gallagher and Michael S. Piwowar with respect to the Commission’s recent adoption of Regulation SBSR which requires regulatory reporting...more

SEC Adopts New Rules, Regulatory Framework for Swap Data Repositories

On January 14, the SEC adopted new rules for security-based swap data repositories (SDRs), which store swap trading data. The rules require SDRs to register with the SEC and set reporting and public dissemination requirements...more

Corporate and Financial Weekly Digest - Volume IX, Issue 49

In this issue: - Delaware Chancery Court Declines to Dismiss Fraud Claims Against Private Equity Fund and Directors - Agencies Amend Regulatory Capital and Liquidity Coverage Ratio Rules - FINRA Proposes...more

CFTC Issues Relief from Certain Part 45 Requirements to Singapore Exchange Derivatives Clearing Limited

On October 8, the Commodity Futures Trading Commission’s Divisions of Market Oversight and Clearing and Risk (Divisions) issued No-Action Letter No. 14-122 providing relief to Singapore Exchange Derivatives Clearing Limited...more

Updated: CFTC FORM 40/40S Reporting Requirements

Note: This version includes an additional section on cross-border considerations. Significant amendments to the CFTC’s large trader reporting program will apply as of August 15, 2014. The U.S. Commodity...more

Financial Regulatory Developments Focus - July 2014

In this issue: - Derivatives - Compensation - Regulatory Capital - Credit Ratings - Financial Market Infrastructure - Financial Services - Funds - Enforcement...more

SEC Proposes Securities-Based Swap Recordkeeping, Reporting and Notification Requirements

On May 2, 2014, the Securities and Exchange Commission (SEC)published in the Federal Register proposed regulations1 that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street...more

SEC Proposes Recordkeeping, Reporting, and Notification Requirements for Security-Based Swap Dealers and Major Security-Based Swap...

The SEC issued a release proposing recordkeeping, reporting, and notification requirements for security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs”). Although described as seeking to...more

Corporate and Financial Weekly Digest - Volume IX, Issue 17

In this issue: - Proposed Amendments to Delaware General Corporation Law and Courts and Judicial Procedure Law - SEC Division of Corporation Finance Issues New C&DIs Relating to Social Media Use - FINRA...more

SEC Proposes Recordkeeping and Reporting Rules for Security-based Swaps

On April 17, the Securities and Exchange Commission proposed several new rules relating to security-based swaps. The rules deal with “recordkeeping, reporting, and notification requirements applicable to security-based swap...more

"SEC Proposes Security-Based Swap Recordkeeping, Reporting and Notification Requirements and Capital Rules for SEC Registrants"

On April 17, 2014, the Securities and Exchange Commission (SEC) proposed new regulations that would implement the recordkeeping, reporting and notification requirements of the Dodd-Frank Wall Street Reform and Consumer...more

CFTC Opens Broad Inquiry Into Swap Data Recordkeeping And Reporting

Following up on its January 21, 2014, formation of an interdivisional staff working group (Working Group) to review its swap data reporting and other provisions of Part 45 of its regulations, on March 19, 2014, the Commodity...more

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